ML17262B206
| ML17262B206 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/15/1991 |
| From: | Eapen P, Lopez A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17262B207 | List: |
| References | |
| M91-048, M91-48, NUDOCS 9105020117 | |
| Download: ML17262B206 (97) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
M91-048 Docket Nos.
A li ted in Attachmen 1
License Nos.
As li ted in Attachment 1
Licensee:
listed in Attachment 1
Participants:
As listed in Attachment 1
Meeting At:
Sheraton Ualle For e Kin of Prussia Penns lvania M
kgl:
d M: l~b2 -2>>
9 Prepared by:
A. E.
- pez, eactor Engineer, Sy tems Section, Engineering Branch, DRS ate Approved by:
Dr. P. K. Eapen, Chief, S stems Section, Engineering Branch, DRS date Meetin~ Summar:
The Engineering Symposium/Workshop was held to promote an open discussion of various industry topics.
The meeting was attended by NRC, licensee, and other industry personnel.
The topics discussed were:
(1) Elements of a good engineering organization; (2) Licensee's actions with degraded conditions, including operability/reportability determinations; and (3) The modification process including 10CFR 50.59 reviews.
The symposium conclusions recommended six action items for the NRC and sev'en action items for the industry.
e ion I Meetin Re ort M 1-04
~bl f
~Pa e 1.0 Purpose 2.0 General Overview 3.0 Summary of Workshop Group Presentations 4.0 Conclusion Attachment 1 - List of Attendees - Meeting Agenda - Speakers Slide Presentation - Workshop Group Summaries
1.0
~Pe ose The Engineering Symposium/Workshop was designed to promote discussion and a better understanding between the utilityengineering personnel and the NRC staff regarding the engineering departments role in support of plant activities.
2.0 The Engineering Symposium was conducted on February 20 - 21, 1991, as published in the Federal Register Notice dated January 24, 1991.
Attachment 1 presents the list of persons who attended the symposium.
An agenda of the symposium is provided in.
The Engineering Symposium began with a Call to Assembly, an Introduction, and a Welcome.
Mr. J. H. Sniezek, NRC Deputy Executive Director for Operations, and Mr. E. J. Mroczka, Northeast Utilities Senior Vice President of Nuclear Engineering and Operations then addressed the symposium.
Both Mr. Sniezek and Mr. Mroczka eloquently discussed the theme of the symposium, "The Engineering Role in Plant Support."
They provided an excellent basis for promoting open discussion during the symposium. contains the slides presented by the keynote speakers.
The afternoon concluded with the attendees participating in the first of two planned workshop sessions.
The participants were assigned to one of the workshop groups.
Two groups discussed the elements of a good engineering organization; three groups discussed the licensee's actions with degraded conditions including operability/reportability determinations; and three groups discussed the modification "process including 10CFR 50.59 reviews, Each workshop group was lead by two facilitators, one each from the NRC and a licensee, and had approximately 15 - 25 participants.
The participants returned the next morning to the same workshop group as the day before for approximately two hours to finalize discussions and to develop recommendations.
At 10:30 a.m. on February 21, 1991, a speaker, Mr. M. R. Tresler, Diablo Canyon Engineering Manager, Pacific Gas and Electric Company, and Chairman of Region V Engineering Managers'orum addressed the symposium.
Mr. Tresler discussed the experiences at the Region V Engineering Managers'orum.
The slides from Mr.
Tresler's presentation can be found in Attachment 3.
4 In the afternoon, the facilitators from each of the eight workshop groups presented a
summary of the their groups discussions and conclusions. contains slides from the facilitators presentations.
The facilitators presentations were then followed by two wrap-up speakers and closing remarks by Mr. M.W. Hodges, NRC Director of the Division of Reactor Safety for Region I. The symposium adjourned at 4:20 p.m.
3.0 Summa f W rk h rou Pre en ions A.
Elements f a d en ineerin or ani ti n The two work groups on this subject concluded the following:
1.
There is no single universal engineering organizational structure that is best for all plants.
2.
A good engineering organization must:
a.
prioritize its activities from a safety perspective and establish clear lines of responsibility and accountability b.
be responsive to the needs of its customer (operations, maintenance,
...)
c.
maintain a well qualified and trained staff d.
maintain a high quality interface with the NRC These working groups did not recommend specific actions for the NRC or the industry groups.
B.
icen ee'cti ns wi h d ed ndi i n incl i
era ili /re rta ili 4
'he three working groups on this subject concluded the following:
1.
fgncgrn<;
a.
lack of well defined concepts and terms for operability b.
lack of well defined processes for operability determination c.
lack of adequate guidance for the use of engineering judgement in operability determinations
2.
d.
lack of adequate guidance for reportability d
a.
NRC establish consistent guidance on operability and reportability (NRC Action Item 1) b.
Industry develop design basis standards with NRC endorsement (NRC Action Item 2, Industry Action Item 1) c.
Industry establish guidelines for the timeliness for operability determinations with NRC endorsement (NRC Action Item 3, Industry Action Item 2) d.
NRC and Industry train their respective personnel in the use of the above guidance (NRC Action Item 4, Industry Action Item 3)
C.
The modification rocess includin l CFR 50.
review The three working groups on this subject concluded the following:
1.
the modification process including the 50.59 process has been consistently improving 2.
NSAC 105 and NSAC 125 are good industry standards to provide guidance in the design process and the 50.59 review process, respectively
~Weal'nesse 1.
design change process is cumbersome 2.
temporary modifications may be bypassing the modification process 3.
design bases are not adequately defined 4.
control of contracted modification work is not adequate 5.
inadequate prioritization and control of backlog
Recommendati ns NRC and Industry train their respective personnel in the modification process (NRC Action Item 4, Industry Action Item 3) 2.
Licensee establish clearly developed design basis documents for each unit using NRC endorsed standards (Industry Action Item 4) 3.
Industry define categories of modification with NRC endorsement (NRC Action Item 5, Industry Action Item 5) 4.
5.
Industry improve NSAC 125 to provide examples of good 50,59 reviews (Industry Action Item 6)
NRC endorse NSAC 125 for 50.59 review (NRC Action Item 6) 6.
Industry establish measures based on safety to prioritize and control backlog of engineering projects (Industry Action Item 7) 4.0 Conclusion The symposium had good participation from all its attendees.
The majority of the feedback forms received, indicated that the symposium achieved its goals, and promoted and stimulated open discussion between the NRC and the industry.
The feedback also encouraged future symposiums in the engineering area.
A small minority of participants did not fully agree with all the conclusions of the symposium and they provided alternate conclusions.
ATTACHMENT1
A.
Re ion I Licensees LIST OF ATTENDEES LICENSEE
~DOCKET LICENSE ATTENDEES 1.
BG&E 50-317 50-318 DPR-53 DPR-69 Charles Cruse Peter Katz Robert Waskey 2.
Boston Edison 3.
Conn.
Yankee Atomic Power Company 4.
Consolidated Edison Co.
of NY 5.
Duquesne Light Company 6.
GPU Nuclear 7.
Long Island Lighting Co.
50-293 DPR-35 50-213 DPR-61 50-247 DPR-26 50-334 DPR-66 50-412 CPPR-105 50-219 DPR-16 50-322 NPF-19 Robert Fairbank Edward Kraft Clint Gladding Joe Bahr John Curr Mike Lee Pete Szabados Kenneth E. Halliday Nelson R. Tonet Jim Byrne Dave Distet Greg Gurican William Heysek James W. Langenbach Max Nelson Ed O'onnor Art Rone Richard Skillman Patrick Walsh Ed Pierpont 8.
Niagara Mohawk Power Corp.
- 9. Northeast Nuclear Energy Company 50-220 50-410 50-245 50-336 50-423 DPR-63 NPF-54 DPR-21 DPR-65 NPF-49 Michael Carson Gregory Gresack Rob Oleck Bill Yaeger Michael Bigiarelli Brendan J. Duffy G. Leonard Johnson John S.
Keenan Edward J. Mroczka R. L. McGuinness C. Fred Sears 10.
PP&L 50-387 NPF-14 50-388 NPF-22 Bob Byram F.
G. Butler W. H. Gulliver J.
M. Kenny George Kuczynski G.
D. Miller D. P. Parsons
LICENSEE all.
PECO 4
a 12.
Power Authority of State of NY 50-352 NPF-39 50-353 CPPR-107 50-333 DPR-59 ATTENDEES Jim Basilio William Bloomfield Wes Bowers Frank Cook Jack Evans Al Fulvio David Foss Cliff Harmon Dave Helwig Frank Hunt Marilyn Kray Rod Krich G. Kernahan Dave Meyers Lou Pyrah David Schra Glen Stewart Kevin Walsh Jerry Gullick Terry Herrmann Gus Mavrikis Steve Smith Uic Walz
- 13. Public Service of NH 50-443 CPPR-135 50-444 CPPR-136 Terry Harpster Joe Vargas 14.
PSE&G 50-272 50-311 DPR-70 DPR-75 Richard Bashall Raymond Brown Moises Burzstein Thomas M. Crimmins Scott Gillespie Lee Griffis Bruce Hall Michael Morroni Bruce Preston Martin E.
Raps John P. Ronafalvy Frank Thomson
- 15. Vermont Yankee Nuclear Power Corp 16.
Yankee Atomic Electric Co.
50-271 DPR-28 50-029 DPR-3 Mark Palionis Dean Porter Peter Anderson John Hoffman William Jones Dave King Robert. Shone George Tsouberous
B.
Licensee Fr r NRC Re ion LICENSEE ATTENDEES ej'
~
Florida Power and Light Toledo Edison Bill Skelley Vernon Watson C.
Other Partici ants OTHER ATTENDEES 1.
Bechtel 2.
Westinghouse 3.
Tenera 4.
Massachusetts Nuclear Engineer 5.
General Electric Nuclear Energy 6.
Stone
& Webster Nancy Chapman
'teve Routh David Schmit Rick Eastering John Elliott James McKerheide Lee Lantz Ajoy Banerjee Thomas Bates Mare Boothby Alan Chan Tim Chitester Louis Hirst E. J.
Hubner Tom Szabo 7.
NUS Corp Florida Michael Johnson Peter S. Jordan Eric R. Smith
D.
The Nuclear Re ator Commission i
OFFICE 1.
HQ 2.
HQ 3.
HQ 4.
HQ 5.
HQ 6.
HQ 7.
HQ 8.
HQ 9.
HQ 10.
HQ 11.
HQ 12.
HQ 13.
HQ 14.
HQ 15.
HQ 16.
HQ 17.
HQ 18.
HQ 19.
HQ 20.
HQ 21.
HQ
- 1. RII
- 2. RII
- 3. RIII 4.
RIV 1.
RI 2.
RI
'3.
RI 4.
RI 5.
RI 6.
RI 7.
RI 8.
RI 9.
RI 10 RI 11.
RI 12.
RI
- 13. RI
- 14. RI
- 15. RI
- 16. RI
- 17. RI
- 18. RI
- 19. RI
- 20. RI
- 21. RI
- 22. RI 23.
RI
- 24. RI
- 25. RI
- 26. RI
- 27. RI
- 28. RI ATTENDEES Bob Capra Jin Chung Dick Clark Al DeAgazio Richard L.
Emch Mort Fairtile Bagchi Goutam Craig C. Harbuck Gary D. Holahan Chris L. Hoxie Eugene Imbro Jeff Jacobson Wayne Lanning Erasmia Lois Dan McDonald James G. Partlow Uldis Potapovs Mark F. Reinhart Jim Sniezek John Stolz David L. Wiggington Caudle H. Julian Francis Jape Mark Ring Johns Jaudon Scott Barber Walter Baunack Lee Bettenhausen Norman Blumberg Fred Bower Suresh K. Chaudhary Rich Conte Larry Doerflein Jacque P. Durr P.K.
Eapen Harold Eichenholz Pete Eselgroth E. Harold Gray Harold I. Gregg Peter Habighorst Sam Hansell Donald Haverkamp Tom Hiltz M. Wayne Hodges Kerry Ihnen Jon Johnson Herbert Kaplan Paul Kaufman Gene Kelly James C. Linville Al Lohmeier Thomas T. Martin Marie Miller
0
OFFICE 29.
RI
- 30. RI
- 31. RI
- 32. RI
- 33. RI
- 34. RI 35'I 36.
RI
- 37. RI 38.
RI ATTENDEES Dan Moy George Napuda retired William Oliveira Steve Pindale Len Prividy John Rogge Glenn Tracy Ed Wenzinger Barry Westreich Peter Wilson
ATTACHMENT2
Symposium/Workshop e Engineering's Role In Support Of Plant Activities AGENDA Wednesda Februar 20 1991 1:00 1:05 p.m.
Introduction 1:05 1:15 p.m.
Welcome 1:15 1:55 p.m.
Keynote Speaker 12:00 12:50 p.m.
Registration 12:50 1:00 p.m.
Call to Assembly Harold I. Gregg Senior Reactor Engineer Division of Reactor Safety, RI M. Wayne Hodges Director Division of Reactor Safety, RI Thomas T. Martin Regional Administrator, RI James H. Sniezek Deputy Executive Director for Operations, NRC 1:55 2:35 p.m.
Keynote Speaker Edward J. Mroczka Sr. Vice President Nuclear Engineering and Operations Northeast Utilities 2:35 3:00 p.m.
3:00 5:00 p.m.
Break Breakout Sessions A.
B.
C.
~To
- 1. C Elements of a Good Engineering Organization Licensee's Actions With Degraded Conditions Including Operability/
Reportability Determinations The Modification Process Including 10CFR50.59 Reviews Room Location Berwyn Room or Devon Room Gladwyne Room, Bryn Mawr Room, or Hemlock Room Radnor
- Room, Merion Room, or Quaker Room
"Zhursda Februar 21 1991 8: 00 10: 00 a.m.
~Tc ic Breakout Sessions Refinement of most significant issues 4
Room Location A.
B.
C.
Elements of a Good Engineering Organization Licensee's Actions With Degraded Conditions Including Operability/
Reportability Determinations The Modification Process Including 10CFR50.59 Reviews Berwyn Room or Devon Room Gladwyne
- Room, Bryn Mawr Room, or Hemlock Room Radnor
- Room, Merion Room, or Keystone Room 10:00 10:30 a.m.
Break 10:30 - 11:30 a!m.
Speaker Michael R. Tresler Engineering Manager, Diablo Canyon Pacific Gas and Electric Company Chairman of Region V Engineering Managers Forum 11:30 1:00 p.m.
1:00 2:15 p.m.
2:15 2:30 p.m.
2: 30 3: 15 p.m.
Lunch First Group Summary Feedback Break Second Group Summary Feedback Breakout Session Facilitators Breakout Session Facilitators 3:15 3:35 p.m.
Wrap-up David R. Helwig Vice President Nuclear Engineering and Services Philadelphia Electric Company 3:35 3:55 p.m.
Wrap-up 3:55 4:15 p.m.
Closing Remarks Zacque P. Durr Chief, Engineering Branch Division of Reactor Safety, RI M. Wayne Hodges Director Division of Reactor Safety, RI
I
(,
t t
'I
ATTACHMENT3
JAMES H. SNIEZEK DEPUTY EXECUTIVEDIRECTOR FOR OPERATIONS, NRC PRESENTATION FOR NRC REGION I - UTILITY SYMPOSI 0 M/WORKSHOP Engineering's Role in Plant Support February 20-21, 1991 Sheraton Valley Forge Hotel King of Prussia, Pennsylvania
0
IMPROVEMENT OF OPERATIONAL SAFETY r
SAFE ENOUGH ARGUMENT r
BACKSLIDE TOWARD INADEQUACY r
PRINCIPLE OF COST EFFECTIVE SAFETY IMPROVEMENT
RESPONSIBILITY FOR SAFETY UTILITY RESPONSIBLE FOR SAFETY
~
NRC IS REGULATOR r
NEED FOR NUCLEAR INDUSTRY SAFETY CULTURE TRUST IS FOUNDATION OF NRC/UTILITY RELATIONSHIP
RELATIONSHIP WITH UTILITIES LICENSE BASED ON TECHNICAL/MANAGERIALCOMPETENCE NRC HANDS OFF, IF TRUE NRC ACTIVE INVOLVEMENT, IF NOT TRUE
~
NRC EMPHASIS ON COMMUNICATION OF EXPECTATIONS UTILITY CERTIFICATION OF PERFORMANCE UTILITY RESPONSIBLE FOR SAFETY EVALUATION NRC RESPONSIBLE TO REGULATE
REGULATORY IMPACT SURVEY a
ESTABLISH MANAGEMENT EXPECTATIONS a
MEASURE IMPLEMENTATION OF MANAGEMENT EXPECTATIONS ESTABLISH A STABLE PROCESS CONDUCT ACTIVITIES IN A PROFESSIONAL MANNER
e 0
REGULATORY IMPACT SURYEY (coNrr~Nueo ACTIVITIES SHOULD CLEARLY ENHANCE SAFETY ACTIVITIES SHOULD BE COST-BENEFICIAL RESOURCES SHOULD BE FOCUSED ON AREAS NEEDING IMPROVEMENT CONDUCT A MANAGEMENT SELF-ASSESSMENT
INSPECTION PRINCIPLES a
INSPECTORS NEED TO ALWAYS BE ALERT FOR SAFETY ISSUES -- EVEN THOSE OUTSIDE THEIR AREA OF EXPERTISE
~
PRIMARY EMPHASIS IS ON SAFETY WITH THE RECOGNITION THAT NRC REQUIREMENTS ARE SUPPOSED TO BE MET REGARDLESS OF SAFETY IMPORTANCE
~
DEGREE OF REACTION/RESPONSE BY INSPECTORS DICTATED BY SAFETY IMPORTANCE ACCEPTANCE CRITERIA ARE BASED ON AGENCYWIDE POSITIONS, NOT ON INDIVIDUALREVIEWER/INSPECTOR DESIRES
INSPECTION PRINCIPLES PERFORMANCE INDICATORS ARE USED TO HELP DETERMINE DIRECTION, SCOPE AND DEPTH OF INSPECTION EFFORT AND ARE NOT A DISPOSITIVE MEASURE OF PERFORMANCE BY THEMSELVES ANALYSIS OF MANAGEMENT EFFECTIVENESS IS BASED ON RESULTS OF MANAGEMENT EFFORTS AND NOT ON ANALYSIS OF
- SKILLS, STYLES OR POPULARITY
~
FOCUS OF INSPECTION IS PRIMARILY ON END PRODUCT;
- NOMEVER, PROCESS OF ENSURING QUALITY ALSO IMPORTANT IN ORDER TO ENSURE CONSISTENT QUALITY
INSPECTION PRINCIPLES STANDARDS OF PROFESSIONALISM OF INSPECTORS EXCEED THE STANDARDS EXPECTED OF LICENSEE PERSONNEL APPLICATION OF REGULATORY EXPECTATIONS IS CONSISTENT FROM INSPECTOR TO INSPECTOR AND FROM PLANT TO PLANT INSPECTION APPROACH AND TECHNIQUES ARE SUCH THAT INSPECTOR AND LICENSEE TIME ARE EFFECTIYELY USED INSPECTORS ARE QUALIFIED COMMENSURATE WITH DIFFICULTY OF TASK
INSPECTION PRINCIPLES a
INSPECTION FINDINGS ARE ACCURATELY AND PROMPTLY COMMUNICATED TO APPROPRIATE LEVELS OF UTILITYMANAGEMENT BOTH DURING AND AT THE END OF THE INSPECTION INSPECTION ACTIVITIES APPROPRIATELY RECOGNIZE THE EFFORTS OF INDUSTRY SELF-EVALUATION ORGANIZATIONS SUCH AS INPO AND DO NOT INTERFERE WITH THE LICENSEE/SELF-EVALUATION ORGANIZATION INTERFACE NRC MANAGEMENT KS PROMPTLY INVOLVED WHEN FUNDAMENTAL DIFFERENCES CANNOT SE RESOLVED BETWEEN INSPECTOR AND LICENSEE
INSPECTION PRINCIPLES IN PLANT SOURCES OF INFORMATION ARE GUARDED IN ORDER TO PROMOTE FREE EXCHANGE BETWEEN STAFF AND INSPECTORS a
COMMUNICATIONS ABOUT THE LICENSEE OR LICENSEE PERSONNEL ARE CONTAINED WITHIN THE REGULATORY FRAMEWORK a
BE RECEPTIVE TO ALL ALLEGATIONS AND TREAT ALL PUBLIC INQUIRIES WITH RESPECT AND PROFESSIONAL
RESPONSE
'INSPECTORS MUST GENERATE AN AURA OF INDEPENDENCE IN ALL DEALINGS WITH THE LICENSEE
w~
SUMMARY
a MOST NRC/UTILITY INTERFACES ARE POSITIVE INTERFACES MUST BE STRAIGHTFORNRD AND HONEST RESULT IN EFFECTIVE AND EFFICIENT SAFETY PROGRAMS I
GREATER NRC EMPHASIS ON PROPER INTERFACES IN THE FUTURE
The Engineering Role In Plant Support E. J. Mroczka Senior Vice President Nuclear Engineering and Operations Northeast Utilities NRC Region I Workshop February 20-21, 1991
'I
"NRC PRINCIPLES OF GOOD REGULATION" Independence Openness Efficiency Clarity Reliability
INDEPENDENCE o
"Nothing but the highest possible standards of ethical performance and professional ism should influence regulation.
o
- However, independence does not imply isolation.
o All available facts and opinions must be sought openly from licensees and other interested members of the public.
o The many and possibly conflicting public interests involved must be considered.
o Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated."
OPE S
o "Nuclear regulation is the public's
- business, and it must be transacted publicly and candidly.
o The public must be informed about and have the opportunity to participate in the regulatory process as required by law.
o Open channels of communication must be maintained with
- Congress, other government
- agencies, licensees, and the
- public, as well as with the international nuclear community."
EFFICIENCY o
"The American
- taxpayer, the rate-paying
- consumer, and licensees are all entitled to the best possible management and administration of regulatory activities.
o The highest technical and managerial competence is required and must be a constant agency goal.
o NRC must establish means to evaluate and continually upgrade its regulatory capabilities.
o Regulatory activities should be consistent with the degree of risk reduction they achieve.
o Where several effective alternatives are available, the option which minimizes the use of resources should be adopted.
o Regulatory decisions should be made without undue delay."
INTEGRATEDREGULATORYREQUIREMENTS, IMPLEMENTATIONSCHEDULE o
"IRRIS provides a simple mechanism that will encourage implementation of plant modifications offering the most safety for resources spent; o
help to evaluate and set balanced priorities for an entire set of pending requirements; and o
help to avoid duplication of efforts to enhance safety."
SEC Y-90-347
CLARITY o
"Regulations should be
- coherent, logical, and practical.
o There should be a clear nexus between regulations and agency goals and objectives whether explicitly or implicitly stated.
o Agency positions should be readily understood and easily applied."
t
REPORTABILITY NRC Guidance Should be Consistent Prompt Reports (10CFR 50.72)
Licensee Event Reports (10CFR 50.73)
Inspection and Enforcement Should be Consistent Inspector-to Inspector Region to Region Degraded Conditions, Operability Determinations, and JCO's
- Terminology and'Requirements need to be worked out.
More Rewards for Self Assessment
RELIABILITY o
"Regulations should be based on the best available knowledge from research and operational experience.
o Systems interactions, technological uncertainties, and the diversity of licensees and regulatory activities must all be taken into account so that risks are maintained at an acceptably low level.
o Once established, regulation should be perceived to be reliable and not unjustifiably in a
state of transition.
o Regulatory actions should always be fully consistent with written regulations and should be promptly, fairly, and decisively administered so as to lend stability to the nuclear operational and planning processes."
CONCLUSIONS "NRC PRINCIPLES OF GOOD REGULATION" are also Good Principles for Engineering Support Independence Openness Efficiency Clarity Reliability NRC and Licensees Working Together as Professionals
ENGINEERING
- ENGINEERING S YMPO REGION V ENGINEERING MANAGERS FORUM Mike Tresler Diablo Canyon Power Plant PQBE Engineering, Manager Roon'1409 333 Mdrket Street San Francisco, CA 94106
I
REGIOH V EHGIHEKRIHO AHAGfRS FORVN REOION 5 ENOlNEERlNO NANAOERS'ORVN BACKGROUND
~ Membership
~ APS
~ PGE
~ PG&E
~ SCE
~ SMUD
~ WPPS PtJRPOSE 0 Meet Quarterly
~ Shared Knowledge I Experience
~ Unified Position I Working Task Forces
~ Improve Communication
HAGIO)V V ENGINEERING MANAGERS FORUM TASK CONPLETEQ
~ Charter
~ DBD Guide
~ Proactive Engineering Guide
~ Design Engineer Training 8 Qualification Guide
~ Management Of Low Priority Engineering Tasks Guide
~ Procurement Eng.ineering Guide
~,
REGION V PROCCIRENENT OCIIDEI.INE
~
Tech. Eval. Of Supplier Qual. / Deficienciee.
~ Spare / Replacement Configuration Control
~ Performance History - CGD
~ Commercial Grade Survey *
~ Location Specific Components 4 Detection Of Fraudulent Materials
- 4 4 Information Exchange
HEGlON Y
"",""""'CTIIfESCISCO
~ Engineering Task Prioritization
~ Set Points
REGION V ENGIHEFHING atatw aeHS FORUM POTENTlAL 8UBCOMNITTEES
~ Performance Monitoring
~ Design Process
~ System Walkdowns
~ Operability
~ Procedure Review
REGlON V ENGIHEERIIV0 MANAGERS FOHVN SENEFlTS -TO DATE Budget I Staffing
~ Leak Repair 90-05
~ EDSFI
~ Setpoints
~ ADV's
~ INPO I NRC Support
~ Issue Definition I Containment Shared Experience At All Levels
REGION V
ENGlNEERlNG MANAGERS FORUM
~ Conflicting Demand On Time
~ Top Level Participation In Task Forces Tension Between Set VYays And New Guidance 0 Documents Must Be Useful 8 Used
~ Variability In D.E. Org., Staffing, Capability And Responsibility
y C
REGION V ENGINEERING MANAGERS FORUM
~ Add Plant To Membership
~ Excellent Point of Reference
~
Tips On Latest NRC Concerns, Perspectives 8 Positions
~ United Position On Critical Issues General Mutual Support Environment
ATTACHMEyy4
~4
ELEMENTS OF A GOOD ENGINEERING ORGANIZATION Group 1:
Facilitators - Ed Wenzinger (NRC), Tom Crimmins (PS&KG)
Industry participants:
16, NRC participants:
5 F ur ke issues a.
C.
d.
priorities (19) responsiveness (15) people (8)
NRC interface (7)
Good en ineerin r anizati n
prioritize plan effectively allocate resources to their work Elements a.
b.
C.
d.
e.
f.
g h.
long-term planning priorities - setting how and who emergent work forced outage plan orderliness vs chaos communication enhanced show proactive nature balance long term and short term Good engineering organizations are responsive to the needs of operations, maintenance, and day to day activities Elements a.
b.
C.
d.
e.
f.
g h.
mission clarity physical involvement joint planning/priorities balance reactive and proactive communications, communications, communications key to maintaining design quality and configuration ops and maint. understanding of basis for and demands of the design balance engineering/design perspective and operations perspective Good engineering organizations maintain a high quality interface with the NRC
Group 1
Elements a.
b.
C.
d.
e.
f.
technical competence proactive assertive engineering communications - listen quality of process/product NRC acceptance of acceptable solution escalate professional differences
~l
Group 2:
Facilitators - Harold Gray (NRC), Fred Sears (Northeast Utilities)
Industry participants:
14, NRC participants:
5 Fa r f r c n i eration a>
b.
there is no single, universal engineering structure or organization that is best for all plants whatever the organization is, it must be clearly defined with respect to responsibilities and accountabilities Attributes a.
continual improvement b.
economical operation c.
common goals d.
teamwork e.
effective self-assessment f.
conformance to requirements g.
well defined, available, usable design basis h.
configuration management i.
lessons learned application j.
new technology usage k.
customer satisfaction Enoineerin concerns - " roblem "
a.
b.
C.
LTA Design Basis - documentation and organization Resource Management 1.
conflicting goals and priorities both internal and external 2.
NRC interface - team inspections 3.
off normal support Ineffective Processes
- internal and external Plant Materials - obsolescence, aging, vetip (vendors), OEM demise/dedication S~olu lou a.
mission b.
strategies c.
responsibilities d.
plans, schedules, priorities, resources e.
communications, education, sharing f.
decision tools
.g.
staff training, development h.
cultivate positive NRC/utility relation
~l 4
Group 2 Qgnclu~si ns a.
no single definition of engineering consider all with engineering or science background and those performing in technical roles to be part of engineering solutions of engineering concerns can be reached by good management practices, including consideration of mission - strategies - responsibilities - accountability, plan,
- schedule, train, educate
. the functions of good engineering are many, but the intent is ~afe, reliabl, economical plant operation.
OPERABILITY/REPORTABILITYDETERMINATIONSAND DEGRADED CONDITIONS Group 1:
Facilitators - Jon Johnson (NRC), Wes Bowers (PECO)
Industry participants:
14, NRC participants:
8 Q.
How does licensee know or determine operability and reportability?
A.
When there is ~ufficien evidence or basis that a component or system meets its ~desi n
~ff i
i IChg p
i d
p
'bH id Chi Th determination must be made in a ~timet manner.
What is sufficient evidence?
Issue Recommendati n/solution Who lack of guidance on operability determinations revise NRC inspection manual to provide improved guidance; transmit manual to licensees NRC lack of guidance on reportability finish owners group guidance on reportability; transmit manual to NRC BWROG develop improved guidance on reportability NRC What i desi n
ases?
~Is ue Recommendation/s lution design bases is unbounded publish design bases standard including guidance and component level utility and NRC endorse refine and clarify functional capabilities clarify WRT safety function clarify WRT
'perability or reportability clarify difference (ifany) between design bases for operability (T.S) and reportability (50.72, 50.73)
Group 1
Timeliness of era ilit determinati n
IssSe ecommendation/solution
~Wh unclear process (accountability priority) use a two step process 1 ~ screen (operability determination) and
- 2. F/U analysis utility/INPO refine timeliness guidance publish/endorse guidance
- use STS LCO action times
.- use IPE/PRA to prioritize NRC/NUMARC lack of knowledge/
utility/INPO sensitivity to staff timeliness needs train engineering support Su estions for im roved uidance for o erabilit clarify that the following can be used
- engineering judgement
- test results
- analysis
- compensatory action
- operating experience
- operating parameters
- current physical condition clarify that PRA cannot be used clarify that unavailability of component not required for safety function does not make system unavailable consider NUMARC guidance on design basis definition and examples
Group 2:
Facilitators - Rich Conte (NRC), Bob Byram (PP&L)
Industry participants:
13, NRC participants:
8 Format
- open forum
- aired concerns
- focused on positive aspects
- selected four key concerns
- positive aspects into process objectives
- focused on key concerns
~b'ective
- assurance of nuclear safety
- clear expectations
- communication/action on generic conditions
- efficient and effective
- mutually agreeable
- eng. involvement in operability/reportability
- clear and consistent
- promote initiative/action
- foster questioning attitude
- training and development
- strengthen design documentation
- work on what's important
- enhance safety cultures that are assumed to satisfy regulatory expectations
- sensitivity to real needs of operator erabilit /Re orta ilit ma'or concern a.
define concepts and terms on operability b.
define the process for operability determinations c.
use of engineering judgement Aside I sue - Re rtabilit a.
b.
groups discussion focus was on operability issue group generally agreed 1.
reportability criteria not to be discussed - residual issues exist but are being dealt with 2.
reportability criteria should remain separate and distinct from operability criteria but properly sequenced with operability determinations
0 A
l
Group 2 Ma'or c ncern No. l - Define conce ts and terms a.
operability workability capable of perf qualification timeliness degraded condition JCO/BCO functionality design basis b.
distinguish postulated events (how far do you go)'versus current configuration events (normal conditions) c.
avoid determinations of inoperability because of lack of documentation d.
once defined as above, distinguish workability versus functionality and/or operability versus qualification a'
c ncern No. 2-Define the roce a.
administrative procedure to address operability determinations (including organization roles and responsibilities) should be left to licensee initiative b.
let (responsibility not defined by group) establish process criteria which focus on:
timeliness, prioritization, quality of documentation, etc. (here again licensee initiative) c.
although the NRC says that the pending guidance contains no new requirements (reports/records procedures),
the reality is the opposite because of licensee initiative to establish controls Ma'or concern N 3 - Use f en ineerin
'ud emen a.
b.
C.
d.
e, f.
recognize its use as variable but viable document the thought process for the engineering judgement encourage people to think demonstrate competence in applying engineering judgement make engineers responsible and accountable for the above initial through final stages of operability determination - how is engineering judgement to be applied
Group 2
$ummary.
b.
C.
disseminate information
- 1. pending guidance
- 2. this conference industry interaction at working level focus on expectation as opposed to prescriptive guidance
10 Group 3 Facilitators - Lee Bettenhausen (NRC), Bruce Preston (PSEE.G)
Industry participants:
13, NRC participants:
10 What value/criteria do you use for operability determinations
- design/purchase specs
- d~esi n
~
(
2.(
(RRAR, RRR, LC..), ~fii~ (
(
(222(dd,
- pressure, etc.)?
1.
technical specification values must be used ifavailable 2.
10CFR safety limits 3.
other-example:
containment fan coil units BTU capacity being tested - is tech spec operability based on 1.
purchase spec - design?
100K 2.
FSAR 80K 3.
Ultimate safety limit - i.ed a containment pressure 60K can current conditions be used also -i.e., river water temp (heat sink)-
yes Operable - ASME code versus tech spec operability 2
2.
GL 89-04 directs that device is inoperable iftest results are in action range-appropriate tech spec LCO should be entered (basis-degradation cause unknown, device could fail immediately)
ASME section XI allows for analysis to change action range value using 50.59, maintaining component operable per tech specs (i.e., enter LCO, do analysis, exit LCO) piie section III, class 3 and B31.1 - a thru wall leak of below minimum wall condition does not automatically equate to an inoperable condition (i.e., analysis of flow and structural impact using LCO time as a marker)
Appendix R, EQ, electrical separation discrepancies versus operability:
'I
Group 3 Qualification problems such as these generally ~t operability problems electrical separation problem does not necessarily call for associated equipment to be inoperable Appendix R equipment still operable but compensatory actions to deal with fire need to be taken operability an issue ifaccident causes failure and loss of emergency function Timeline s f erabilit calls no new NRC regulations utility develops written policy; elements include:
a.
b.
C.
prompt initial screen by knowledgeable group timeliness commensurate with safety significance and plant conditions; tools:
PRA, LCO action statements detailed evaluation to support initial screen decision within time bounds, e.g.,
3 days How sh uld o erabilitv uidance be romul ated?
1.
2.
3.
4.
5.
NRC incorporate in inspection manual and by generic letter (in progress)
NUMARC/INPO take initiative for industry guidance, e.g., NSAC (need next month) plant unique program with region buy in NUREG or regulatory guide for utility to construct program do nothing The group favors //2
12 MODIFICATIONPROCESS INCLUDING50.59 REVIEWS Group 1
Facilitators - P. K. Eapen (NRC), Nelson Tonet (DLC)
Utilityparticipants:
6, NRC participants:
6 Discussion to ics 1
~
50.59 review process 2.
temporary modification process 3.
design change process
- reviewed strengths and weaknesses
- developed recommendations for improvement strengths NSAC 125 effective resource utilization weaknesses needs standards needs guidelines for results lacks consistent training required recommendations/comments good DBD, reduce potential (or inadequate safety reviews improve NSAC 125 with samples of adequate/good evaluations for short term utility should develop standards individually enhance NRC inspector training em ra modificati n r
e strengths timely and effective utilization can help to keep the plant safe provides more effective utilization of resources
Group 1
13 weaknesses can bypass modification process challenges configuration control reviews may lack detail can become numbers game recommendations/comments better define maintenance vs mod upfront good DBDs needed to properly manage process 3.
desi n chan e
r cess strengths controlled process maintains DBDs controls plant configuration weaknesses process perceived as cumbersome potential AE or contractor interface problem daily plant support may detract potentially excessive reviews performed recommendations/comments DBDs essential to be successful integrated living schedule provides for effective backlog control regulators/inspectors need better training to understand processes
~Cncln l ns design change process continues to improve further training needed NSAC 125 enhancements could be beneficial effective screening is necessary integrated scheduling can provide more effective resource management
14 Group 2 Facilitators - Jim Linville(NRC), Bill Yaeger (Niagara Mohawk)
Industry participants:
7, NRC participants:
4 tren th f
rocess there has been a significant improvement in safety as a result of the 50.59 process 50.59 process has improved greatly in the. last few years.
It is more substantial and better documented.
Less perfunctory NSAC 125 and design basis reconstitution have contributed significantly to these improvements 50.59 process appears to work well for major modifications Ma' roblem areas difficultyin applying 50.59 process to the modification process commensurate with the nature of the modification major modifications minor modifications temporary modifications (including electrical jumpers and lifted leads) generic modifications design equivalent changes non-safety related systems
~Gal maximize safety minimize resource impact Recommendations for indu tr clearly define modification categories and which parts of the review process are applicable in order to minimize resource impact develop screening process similar to that suggested in NSAC 125 establish well developed design basis establish generic processes to the extent possible ecommendations f r NRC publish a position on the acceptability of NSAC 125 Establish clear staff guidance on application of position train NRC staff on application of guidance manage inspection and enforcement of guidance to provide consistent application with focus on potentially safety significant oversights
e
'l
15 Group 3 Facilitators - Gene Kelly (NRC), Charles Cruse (BGEcE)
Industry participants:
10, NRC participants:
4
~Stree ths 50.59 gives flexibilityto utility good 50.59 process helps clarify design basis 50.59 process gives engineering a better understanding of design basis 50.59 process fosters well documented and assessable design basis NSAC 125 fills long standing void 50.59 enables integrated multi-disciplinary review 50.59 process started early helps provide design framework Concerns/
r blems in rioritized order what is the safety analysis report (scope, detail, referenced documents) does 50.59 apply to as-found, design basis reconstitution "findings" "changes" - where do they "end?
How far should 50.59 be applied?
distinction between licensing and design bases threshold for "temporary" modifications distinction between safety related and important to safety (and definition of the latter)
NSAC 125 "in progress" change clarity 50.59 review of procedure changes scope/criteria for "screening "processes measures of 50.59/modification effectiveness Problem l - what is SAR?
recommendations provide guidance on whether emergency plan, environmental report, and like documents are part of the SAR management meeting between NRC and utilities (NUMARC) incorporate guidance in NSAC 125 delete items not important to safety from SAR add documents clarifying "licensing basis" to next SAR update (SERs, GL responses)
~rblem2-doe r
essa 1
t "sf nd" ei n
r terna dei n
asia 50.59 process does apply to "as found" design problems develop "tiger team" of small dedicated engineering/licensing group to address "as found" design problems - use screening process
C
Group 3 16
~Problem ow far hould S0.59 recess be a lied?
resolve problem 1 (SAR question) clarify need for 50.59 process procedure changes temporary mods long term equipment outages (silent mods) develop screening process provide training on screening criteria add step at end of mod process to perform self assessment of 50.59 process
~onclusi ns NSAC 125 is a good start,but it need additional clarity what is SAR temporary mods procedure changes in progress work definition of important to safety
UNITEDSTATES NUCLEAR REGULATORY CPMMISSION NAOHIND'TON,0. C t00bb levember 9, i990 Hr. ghllfam H. Ras(n Dfrecior, Technfcal Dfvfsfon Nuclear Management and Resources Councfl Sufte 800 1716
%ye Streei K.R.
Vashfngton, DC 20006-2496 lear Nr. Rasfn:
Me have revfewed the "Desfgn Sasfs program Sufdelfnes" develooed by the Nuclear management end Resources Councfl
{KUNARG) forwarded to us by llNARC's letters of Nay 16, July 2, and October 17, 2990, ice apprecfated the opportunffg to fntarface wfth your staff durfng the development of the gufdelfnes.
ice note that your staff was responsfve to the ceanents and concerns that the 4.S.
Kuclear Regulatory Comfssfon (KRG) staff expressed dur5ng the development of the gufdelfnes, lte belfeve that KVNRC's approach wfll provfde a useful framework and worth-while fnsfghts to those usaf lftfes undertakfng desfgn basfs prograIIs Of varfous scopes.
Me share your vfex that no sfngle best approach exfsta for a desfgn basfs program.
Me understand that utflftfes eIust often address unfque sftua-tfons.
Therefore, a varfety of approaches can satfsfy the basfc need to develop a centralfxed locatfon for desfgn bases fnforaatfon that eaphashes the desfgn fntent and provfdes an fndex to faportant desfgn documentatfon.
Lt fs faportant to stress that a facflfty should not be aodfffed unless aufffcfent fnformatfon fs avaflable to demonstrate that adequate des5gn <<argfns wfll be Iafntafned.
He belfeve thai Sectfon Vl of ihe gufdelfnes regardfna valfdatfon of the facflfiy agafnsi current desfgn fnforwatfon fs of par45cular fseortance.,
The goal of any desfgn reconstftutfon program should be to Istablfah conffdence that the exfstfntI facflfty fs fn accordance wfth ihe currant desfgn documents and thai any devfatfons are reconcfled.
The Enclosure suIIIIIarfzes our thoughts on several areas that the NARC gufdelfnes do not address extensfvely.
You Nay want to consfder fssufng further NNARC gufdance 5n these areas as you reccfva responses free utflftfcs on use of the gufdelfnes.
in the near future, the KRC wf11 fssue a NVRE8 doculent contafnfno perapectfvcs on utflfty desfgn control prograIIs and desfgn docuiant reconstftu fon IIrograms gafned from a survey of the prograas of sfx lfcensaes and one ave)ear atlas supply system vendor.
The NURE6 document wfll contafn factual fnfoaatfon regardfng programs as they were befng feplemented at that tfme and wf11 des-crfbe program strengths and weaknesses and problems encountered by otflftfes.
Nr. Nll'lian R. RaalnO We view your development of the "Design Basis Program Guidelines'o be a
positive step in an area that will continue to be of great importance.
Sincerely, Or)ginal signed by:
William T. Russell, Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation
Enclosure:
~
HRC Observations of Design Document Reconstitution Programs Distribution:
~iy, ii HLThompson, EDD
- ELJordan, AEO5 TEMurlm, NRR WTRussell9 HRR FPGillespie, HRR
- CDSngre, HRR
- CERossi, NRR BDLiaw, HRR
- EVImbro, HRR
- EWBrach, NRR
- ETTana, HRR-5483 MOcAlIister, KRR-5483
- NMHodges, RI AFGibson, RII HJMiller, RIII
- LJCallan, RIY RPZiamerman, RV PDR DRIS R/F JHSniezek, ED0
- BKGrimes, NRR blDLanning, KRR RAGrasins HRR
- PFMcKee, HRR MCDrldnera EDD-5493
- TTNartln, A1 SDEbneter, RZI ABDavis, RIII RDMartin, RIV
- JBMartin, RV Central Files EDO R/F RSIB R/F
<<See previous concurrence RSIBlbRIS SC'RSIB:DRIS C:P:
1$
ailler*:bt EYImbro*
1 ing 20/25/90 10/25/90
/
/90 Qe ADT:NRR Tach E
B MTRusse1 1 10/17/90
/5 /90 10/ 5'/90
NRC Coaeents on Design Document Reconstftutfon programs ENCLOSURE (2)
Tem late A
roach The desfgn document reconstftutfon (DDR) process should result Q confi-dence that sufffcfent desfgn documentat5on fs avaflable (a) to verffy the fmplementotfon of the desfgn bases, (b) to provfde 4ustfffcatfon that key desfgn parameters, such as the pump net positive suctSon head, are ade-quately accounted for fn the design, and (c) to ensure that a structure,
- system, or component
{SSC) will perform fts fntended safety functfon.
One approach to developfng a system or topical desfgn bases document fs to first identify a template of design parameters.
Such a template itould (a) establfsh and define the functfonalfty and operabflfty requfrements of SSCs,
{b) demonstrate the conformance of SSCs to the desfgn bases, and (c) demonstrate that SSCs vill perform thefr Sntendad safety functions.
A revfew could then be performed to establish the degree to whfch the available design documents support the pirametirs defined Sn the teaplate.
This process would fdentffy <<reas that require addftfona1 design documentatfon.
Desf n Document Technfcal Review The design document reconstftutfon program should fnclude a technfca1 revfew of the supporting design parameters, design calculatfons, and analyses.
This technical revfew would verify that the design documents are technfcally sound and consistent efth the as-buflt facfif+.
The aveflable design documents should be reviewed to fdentffy areas where desfpn information fs technically fnadequate or not consistent sfth the as-built facflfty.
(3)
Conce t af Fssentfal Desf n Documents In performfng a design document reconstftutfon program, certafn design documents wfhl probably be unretrfevable or vill contain fnconsfstencfes.
Mhfle the NRC does not advocate the regeneratfon of the complete set of design documents, ft fs fmportant that certafn desfgn documents are avaf)able to support plant operatfon.
The desfgn documents 4n this set irfll be referred to as the 'essentfa1 design documents" and are further deffnad as Category I herein.
All Category 1 desfgn documents east be
- accurate, and those that are unretrfevable need to be regenerated.
Category I design documents are those documents that are necessary to support or demcnstrate the conservatism of technfcal specfffcatfon values, such as pump flow calculations or setpofnt calculatfons.
Addftfonal design documents fncluded fn Category I would be those necessary for a) engineering organfzatfons to use fn supportfng plant opcratfons and b) the operators to use fn qufckly responding to events.
Examples of Category I documents fnclude, but are not lfalted to, a'Iectrfcal
'broad
lfsts, setpoint lists, valve lfst.s, 5nstrument 'lists, fute lists, breaker
)fsts, g-lfsts, dfescl generator
)oad sequenC5ng, piping and 5nstrumenta-tfon.diagrams, fla diagrams, electrical single line dfagrais and schemat-ics, and breaker and-fuse coordination studfes.
(4)
Prforftfzatfon of Nfssfn or Inade uate Documents Use of a prforftfzation Iethodo')ogy in considering whether ta regenerate mkssfng or def)cient documents can ensure that the licensee focdhes resources on the cere safety-significant items in a timely aanner, An initial screening process would enable the licensee to detarmfna the
, sfgnfffcance, effect on plant operability, and reportabflfty requfroments
'elated to the Ifssfng or inadequate docuaentatfon.
One way to rank the importance of design docuients according to safety sfgnfffcance is as fol)o<<ts:
Category I bcsfgn documentation that supports or defines technical specfffcatfon safety limits, limiting condftions for operation, limiting safety system setpofnts or survefl lance requfrements.
These docuiints oeienstrate that the SSCs addressed by technfcal specifications will perform their active safety functions.
Category II - Design documentation that defines controllinp paraeeters or demonstrates the active functionality of safety-related SSCs that are not explfcftly addressed by the technical specifications, but that support the SSCs addressed by technical spec1ficatfons such as heating, ventflatfng, arid afr condftionfnp systems.
Category III - Design docuientatfon that defines controlling parameters or demonstrates cctfva funct1onality of safety-related SSCs not included 5n Categories I or II, Category IV - Desfgn documentation that defines controlling parameters or demonstrates the functionality of safety-related SSCs with regard to passive considerations {e,g acfsmfc considerations).
Category V - Design documentat1on that demonstrates the design of non-safety SSCs 5s such that its faflure would not impafr the functiona'l55y of safety-related SSCs {c.g., seismic
?I/I considerations).
(5)
Desi n Bases vs. Desi n Document Reconstitution Reestablishment of the design bases without reconstitution of the Iupport-ing essential design documents aalu not provide a sufficient amount of fnkormatfon to support future aodfffcations and current plant operation, The obgectfve of a DDR program is to establish a continuity among the various levels of design information (e.g., desien calculations and design bases documents) and with the physical plant characteristics of the
- facflftI, The DDR program should ensure that the design bases documents accurately reflect the source design documents.
the design output docu-ments accurately. reflect the design bases, and the plant configuration 5s fn accordance wfth the design output documents.
Thks
$ nfarmat3on quar)ng docvmcnt reconst$ tut$ on he evaluated 4n relation to the document categor)es, as def)ned heraln.
The NRC cons)der s that ill Category I essent)al documents that are inaccurate, unretrfevable, or not ye% oroduced should be regenerated
$ n en expeditious aanner.
- However, e 'licensee Nay be able to generate test data or use other aeans to estatl)sh a hfgh level Of conf)dence that the stysteal can fu)fillfts safety funct1ons.
If so, then the licensee aalu be 'able to schedule the regeneration of the Category I document
$ n a period of tive coeiensuratc w)ttl Cts eyaluatad safety s{gn$ f$cence.
A licensee ey not need to regenerate des)gn documents for Catcgor)es II through Y
$f other supporting lnforwat)on or test 4ata ls eve)liable to demonstrate that en SSC can perform its contended safe function.
For exampleg )t asy not be necessary to regenerate all abyss)ng ptpe support calculations
$f, based on reana)ysfs of a suft$ c$ent seep]e,
$t can be demonstrated that adequate des)gn anrg$ ns exist.
- However,
$f e aed$ t3cat$ on 3s proposed that would affect a p$ pe support,
$t would have to be reanalyzed ff a valid enalys$ s d$ d not ex)st.
It
$ s Important to stress that a facial)ty should not be Iod1f)ed unless cufflc1ent 1nformstkon ls eve)labia to demonstrate that adequate design smrglns m111 be malnta(nad.
Therefore all mlsslng calculations or design documents necessara to support e modfflcatfon must be regenerated to establish a poles of departure for the proposed modlf1catlon and to quantify the design Iargfn available following the proposed fnstallatkon of the aadif)cation.
0